Last Updated: 1 January 2020
We are careful and do not use consent light-hearted as a legitimate ground for processing personal data as a one-size-fits-all solution. We adopted all the measures that are legally required for its work in commercial intermediation in digital marketing and, more specifically, in the field of protection of personal data.
MPP handles everyone’s privacy carefully. In order to do so, MPP adheres to privacy legislation, as stipulated in this section, in addition to legal standards which are dictated by approved codes of conduct. MPP complies with the requirements of the current applicable privacy legislation for an accurate processing of personal data, where under The California Consumer Privacy Act of 2018.
Pursuant to California’s privacy law, into effect on 1st January 2020, we have revised our Privacy Notice to include the following principles of data processing.
Consent and explicit opt-in
In accordance with our data processing operations we have checked if your consent is the most appropriate basis for processing. We ask our customers and respondents to positively and explicitly opt-in prior to any start of the processing. The request for consent to you is made prominent and separate from any conditions that may apply to the promotions you have participated. Your consent is (also) used to administer the campaigns you are interested in. If you withdraw consent you contact data is blocked until you have given your consent again. Any given consent is never made on a default mode. We keep a record of when and how we received your consent on an individual identifiable basis. We also keep a record of exactly what you were shown or told at the time of participating to the campaign. For email specifically, by registering, you are giving explicit consent (permission) for your email to be shared with third parties for the purpose of sending third party email communications until you withdraw your permission.
Should you have questions about the campaign to which you participated in, then please contact our privacy officer at [email protected] who can reply to you directly for any question or concern you may have.
We would like to specify to you why we process data and what we’re going to do with it, for which purposes data are going to be used and further processed.
Consent or withdraw
We give individual options to consent or positively and explicitly opt-in to different purposes and types of processing. We name our organisation and any third party businesses who will be relying on the consent at the moment of collecting your data. We inform our customers and respondents that they can withdraw or refuse their consent without detriment. We perform on withdrawals of consent as soon as we can and direct our customers and respondents how to do so. In offering online communication directly to our customers and respondents we seek consent in accordance with and necessary for the purposes of our data processing operations and our relation with you. We have age-verification measures (and parental-consent measures for younger children) in place to avoid that children (below 13) and youngsters (13-18) can participate to our services.
Categories of data
The categories of personal data which are necessary to provide the services are:
- the customer’s and respondent’s first and surname, title, gender, date of birth, address, postcode, place of residence and similar data required for communication by the person concerned.
● contact data such as (mobile) telephone number and email address.
● consent data including name, surname, e-mail address, IP adres and copy of campaign materials.
● preferences or (confirmed) opt-in requests how to be contacted via email, mobile phone number and sms or mms.
● opt-out request not to be contacted for marketing purposes at all.
● preferences for different kinds of promotions, goods or services.
● prize winner data, including photo of the prize winner when disclosed.
● further information requests and/or contact history.
Sharing of Personal Data
Charity, Telecoms, Telecommunication, Utilities, Mobility, Home Improvements, Broadcasting, TV, Wills, Funeral Plan, Retail, Automotive, Shopping, Beauty and health, Cosmetics, Financial services (only contact data), Travel, Leisure, Sports, Games, Trivia and mobile service providers.
Do know that we do not sell or share your personal data without your prior informed opt-in consent.
Sharing of personal data, examples of data disclosures are:
We may share and/or sell Information that we have about users in many ways and for many purposes, for which we may be compensated, including the following (see below for a description of the augmented rights that California residents have with respect to opting-out of the sale of their Information):
- With our advertisers, marketing partners and service providers for marketing purposes;
- With our telemarketing partners where we have obtained your “prior express consent” (as defined by the TCPA) to be contacted by one or more of our advertisers;
- With our vendors and marketing partners that assist us with delivery of email messaging, telemarketing calls, text/SMS messaging and push notifications, both commercial and transactional in nature;
- With our interest-based advertising partners, as described further below, including to create anonymized sets of Information which are made available for use by third-party advertisers for programmatic advertising purposes;
- With our Related Entities to augment and verify the Information we collect and to develop and enhance their products and services;
- With one or more vendors who provide independent verification of consent, including verification of consent under the TCPA;
- To enable third parties, including our data and list management partners, to market products and services to you;
- To enable customer service vendors to perform their respective tasks, including for fulfillment of Promotions;
- To enable our Information verification and fraud detection vendors to perform contracted for services; and
- To submit users’ contact information to comment and petition campaigns run by governmental agencies, elected officials or other parties where users have provided their express consent to endorse and be a part of the campaign including, in some instances, appending the user contact information with specific comment language.
When we share and/or sell Information, we enter into agreements that describe the purpose for which the Information is shared/sold, restrict its use to the agreement’s specified purpose and require that all Information remain confidential, and be protected from unauthorized disclosure.
Medicare Supplement plans disclosure
Some of our third-party advertisers offer Medicare Supplement plans. Medicare Supplement plans are not connected with or endorsed by the U.S. Government or the Federal Medicare program and all related offers on our Websites comply with applicable Federal civil rights laws and do not discriminate on the basis of race, color, national origin, age, disability, or sex.
Commercial and legitimate interests
These categories of personal data, we process, are processed for purposes which are based on commercial and legitimate interests in accordance with the laws and regulations. The legitimate interests are our own interests and the (commercial, legitimate) interests of third parties to provide you with the offers you would like to receive. The promotions contain not only offers which benefit our customers’ and respondents’ contact preferences (see above) but also apply to educate you about discount offers and for that purpose sending the correct email and sms on the right moment. In order to balance the commercial interests with your privacy preferences we never collect or ask for more data than is necessary for a proper operational performance of our online communication.
Why does Media Pay Plus Ltd collect personal data
We process data when such is necessary for:
- the responsible management of MPP’ online communication.
● providing the option to register or unregister for specific user interests.
● processing interest(s) in product or service categories which are offered.
● operation of customer services, such as answering questions and block personal data on the first request of the data subject.
● processing of traffic data (inbound clicks, testing, log files where needed) and analyse these to detect fraud and redemption.
● offering the option to use mobile device as a form of identification to obtain or purchase services from other organisations and address the benefit of the data subject therein.
● if applicable, the conclusion or performance of a contract concluded in the interest of the data subject between the data collector and partners.
● the (further) performance of another legal obligation.
Information is not automatically used for all these objectives simultaneously.
Online (direct) communication
Data required for online (direct) communication are processed in accordance with the following requirements.
The processing is intended for communication with data subjects, sending information about the products and services of partners, keeping an overview of the information sent and maintaining the contact with the data subjects.
No other personal data will be processed than:
a. surname, first names, initials, title, gender, date of birth, address, postcode, place of residence, telephone number and similar data required for communication by the person concerned;
b. data relating to the information to be sent and transmitted;
c. other additional data that are necessary with a view to maintaining contact with the involved data subjects.
The personal data are only provided to those Sponsors, who are in charge of or direct communication with the data subject or who are thereby necessarily involved.
The personal data will be deleted at the request of the data subject or no later than two years after the relationship with the data subject has terminated, unless the personal data are necessary for compliance with a legal obligation to retain data.
Data required for security reasons are processed in accordance with the following requirements. This policy only treats a selection of items. Of course, it shall be clear to secure the entire data processing process, including the secured communication lines.
The processing is intended for the control and security of the systems or programs, the support of the proper functioning of the systems or programs, sorting and recovering files, creating backup copies of files, the management of the systems or programs.
No other personal data will be processed than:
a. data relating to the use of the software,
b. technical and control data,
c. data to promote proper functioning,
d. historical data,
e. user data.
The personal data are only provided to those, including third parties, who are in charge of or direct the system, data management or application management or who are necessarily involved and others, as the case may be, to the (further) performance of another legal obligation.
The personal data will be deleted at the latest 6 months after they have been obtained, unless the personal data are necessary to comply with a legal data retention obligation.
Data required for processing operations concerning prize winners are processed in accordance with the following requirements.
Processing is only for company purposes to inform who were the prize winners.
No other personal data will be processed than
a. initials and surname of the prize winner.
b. photos and video images with or without sound.
The personal data will be deleted after termination of the website or will be immediately deleted at the request of the data subject (prize winner).
Combinations of processing operations
Your individual rights
What are your rights relating to processing of my personal data?
You have the following rights:
• Information and access: We tell you which of your personal data we are storing and for what purposes.
• Rectification: Please let us know if you want to have your personal data corrected or supplemented because they are incorrect and/or incomplete. We will change them accordingly.
• Deletion: You can also submit a request for us to delete your data. We cannot delete data when the law requires us to retain the personal data in question. We may also have to be able to process the data for other purposes (administrative).
• Limitation: You can impose limits on processing of your data if you feel that your data are processed unlawfully or incorrectly.
• Objection: You can submit an objection against processing of your data. If this relates to processing for direct marketing purposes, we will terminate the processing as quickly as possible.
If you no longer with to receive direct mail, you can:
– Unsubscribe via any marketing mail
– Change your account settings
• Lodge your complaint to https://customercare.today/us/ in order to opt-out of third party data operations and have the data deleted or removed on your request.
Browsing session and IP-address
We also make use of the IP-address of your computer. This IP-address is a number which automatically assigned to your computer when you have a browsing session on the internet, such as when you visit one of our sites or landing pages. They can be used to see which use has been made of the website and for drafting analyses and reports with non-identifiable information.
Website and cookies
- remembering and communicating information that you fill in during the entry process or that you enter when indicating your interests in the various web pages, so that you don’t have to re-enter the same information every time or see the same promotions twice,
● saving of preferred settings, and
● tracking the unauthorised use of our landing pages.
‘Analytical’ cookies are used to analyse your visit to our websites. We analyse the number of visitors to our websites, the duration of the visits, the order of pages visited and whether any changes need to be made to the website. Using the information collected, we can make our websites even more user-friendly. These cookies are also used to solve possible technical problems on the websites.
Marketing and tracking cookies
We will only use tracking cookies for commercial purposes with your prior consent. These cookies, which are often posted by third parties, help us to tailor promotional offers to you personally. Third parties can use tracking cookies.
Questions, complaints or disputes
You can contact us by writing or email us at the address below:
Arch. Makario III, 161; 5th Floor/ Office 5; 3027 Limassol, Cyprus
or through: https://customercare.today/us/
1 January 2020